A person who willfully [tampers with tangible property of another person so as to endanger person or property] [damages tangible property of another person] is guilty of criminal mischief.

DEFINITIONS

[Insert relevant definitions. NDCC 12.1-01-04 and 12.1-02-02]

ESSENTIAL ELEMENTS OF OFFENSE

The State's burden of proof is satisfied if the evidence shows, beyond a reasonable doubt, the following essential elements:

1. On or about the ____ day of _______________, 19__, in ______________ County, North Dakota, the Defendant, _______________, willfully [tampered with _____________, tangible property of _____________, so as to endanger persons or property] [damaged ___________________, tangible property of _____________________].